Sonny Boy Oats, Jr. v. State of Florida

Sonny Boy Oats, Jr., appeals an order of the circuit court that denied his motion filed pursuant to Florida Rule of Criminal Procedure 3.203, 1 in which he claimed that he is intellectually disabled 2 and thus cannot be sentenced to death. In light of developments in the law since Hall v. Florida, — U.S. -, 134 S.Ct. 1986, 188 L.Ed.2d 1007 (2014), and because the circuit court erred in its legal analysis regarding the onset of Oats’s intellectual disability prior to the age of 18 and failed to consider all of the evidence presented, we reverse and remand for a full reevaluation of whether…